Uruguay
Overview
Uruguay’s framework is centred on Comprehensive AML Law No. 19.574 of 20 December 2017 and its implementing/supervisory rules. Law No. 20.469, promulgated on 19 March 2026, materially amended Law 19.574 and related statutes, so the Deep profile treats it as a current reform layer distinct from the 2020 GAFILAT MER.
Beneficial-owner transparency is embedded in customer/legal-person identification obligations and Uruguay’s wider transparency framework. The Deep layer uses the 2020 MER for effectiveness findings and the 2026 statutory amendment for current law, without assuming that the newer text retroactively changes the assessment baseline.
Suspicious reporting is routed through the national financial-intelligence architecture, with SENACLAFT and BCU/UIAF guidance applying according to sector. Law 20.469 amends several AML provisions and related institutional statutes. SENACLAFT’s 4 September 2026 guidance confirms that non-financial obliged entities may use third parties to assist with CDD but remain responsible for the final CDD result; SENACLAFT does not authorise or register those service providers.
Compliance Calendar2
Requirement
Reporte de Operación Sospechosa (ROS)
Authority / Report toUIAF, Banco Central del Uruguay
Deadline / triggerPromptly / without undue delay under the applicable regime; no single national numeric clock asserted.
Requirement
- Subject scope
- Financial and non-financial obliged subjects under Law 19,574 and applicable rules.
- Trigger
- Detection/analysis meeting the suspicious-operation standard.
- Filing channel
- Applicable UIAF reporting channel.
Impact
- Consequences of non-compliance
- Failure to report can lead to regulatory/administrative sanctions and other consequences.
- Enforcement authority
- BCU / SENACLAFT / competent authorities according to sector
- Operational impact
- Treat ROS as prompt reporting and verify the sector detail before setting SLA.
Requirement
AML/CFT risk-based preventive controls
Authority / Report toBCU or SENACLAFT / relevant supervisor
Deadline / triggerOngoing; CDD, beneficial-owner identification, risk assessment, monitoring, recordkeeping, training and governance.
Requirement
- Subject scope
- Obliged subjects under the applicable financial or non-financial regime.
- Trigger
- Continuous conduct of covered activities.
- Filing channel
- Internal framework and supervisory evidence.
Impact
- Consequences of non-compliance
- Control deficiencies may lead to sector-supervisory sanctions/remediation.
- Enforcement authority
- BCU / SENACLAFT / competent supervisor
- Operational impact
- Keep financial and non-financial supervisor obligations separated.
Authorities & FIU1
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. Follow-up reports do not normally replace these ratings.
Explore 40 FATF RecommendationsSee every Technical Compliance rating and what it means.+
Explore 11 Immediate OutcomesSee how FATF rates whether the AML/CFT system works in practice.+
Regulatory Timeline39
SENACLAFT issued a communication on 4 September 2026 clarifying the use of professionals or specialist firms to assist non-financial obliged entities with customer due diligence. The obliged entity remains responsible for the final CDD result and cannot delegate that responsibility to a third party.
SENACLAFT issued Resolution 61/2026 establishing new guidelines for applying sanctions to non-financial obliged entities for failures to comply with AML prevention rules.
SENACLAFT issued Resolution 54/2026 for non-financial fiduciaries and providers of administration, accounting or data-processing services newly covered by Law No. 20.469. The resolution requires registration with SENACLAFT and establishment of an electronic domicile (DOMEL).
Law 20.469 changes multiple provisions of Law 19.574 and related statutes, creating a new current-law layer after the 2020 MER.
Decree No. 43/026, promulgated on 25 February and published on 9 March 2026, amends Decree 77/017 implementing Law 19.484 on international tax transparency and prevention/control of money laundering and terrorist financing. Most amendments apply from 1 January 2026, while specified beneficial-owner information changes apply from 31 December 2027 for relevant reportable accounts.
SENACLAFT published Uruguay’s National Strategy against money laundering, terrorist financing and proliferation financing for 2025–2030. The strategy was approved by Executive Decree No. 155/025 and establishes 22 objectives with concrete actions through March 2030.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Uruguay published Law 19.574, consolidating the national anti-money-laundering and counter-terrorist-financing legal framework.
Law 19.574 becomes the central modern statutory framework for AML/CFT prevention, offences and obliged entities.
The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Egmont Group's official Member FIU Information register records Uruguay's FIU admission date as 2010-06-29.
Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
Current UN depositary relationship to 2003 UN Convention against Corruption. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗GAFILAT records Uruguay among the nine governments that signed the constitutive Memorandum of Understanding on 8 December 2000.
The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
Current UN depositary relationship to 2000 Palermo Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
Current UN depositary relationship to 1999 Terrorist Financing Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
UN Members agree to accept and carry out Security Council decisions. This current Charter relationship is not proof of the jurisdiction’s domestic implementation, nor a claim about its membership status on the historical event date.
UN Charter · Article 25 ↗FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
Current profile relationship to the Egmont network. This does not imply membership in 1995; admission history is a separate LOCAL/STATUS fact.
Egmont Group · Member FIUs ↗FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
Current UN depositary relationship to 1988 Vienna Convention. This is not a claim that the jurisdiction was already a Party on the GLOBAL event date; the national accession/ratification date is a separate LOCAL/STATUS fact.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗